Extract to table

TMC must be prepared to do so

The Yates Memorandum requires that, to receive any cooperation credit, a corporation must provide all relevant facts about the individuals involved in the misconduct

TMC is not eligible for leniency and must pursue cooperation credit through other channels, most likely through an NPA or DPA negotiation

Holt, for his part, seeks to suppress or limit precisely the kind of evidence that TMC must provide to demonstrate its cooperation bona fides

Implications for Other TMC Witnesses In addition to Holt, the internal investigation has identified two TMC employees whose conduct and knowledge are relevant to the investigation and whose individual exposure must be assessed